Excerpt from letter to Frank Cianfrani, Chief, Regulatory Branch, U.S. Army Corps of Engineers, Philadelphia District:
It is critical that Section 106, NEPA and all Clean Water Act decisionmaking undertaken by, and overseen by, the Army Corps be above reproach in all instances. The Sugarhouse Casino development proposal is highly controversial and as a result even greater vigilance should be applied.
I urge the Army Corps to take a step back, to sit with the Consulting Parties in conversation and to discuss the outstanding concerns that have been so often raised and documented, and yet so clearly ignored.
From communications that have been circulated, other Consulting Parties clearly agree on the need for a meeting and discussion, including John Gallery of the Preservation Alliance who wrote: “the information is complex and the differing views are often difficult to understand and evaluate… It is difficult for us to evaluate the different points of view from these multiple emails….Given the lack of agreement, the Preservation Alliance would prefer that a meeting of all parties be held and that work on the site be halted until such a meeting and discussion can be occur.”
As things stand, the Section 106 process and outcome is sorely in question and the Army Corps in our view cannot be said to have fulfilled its obligations including the one to “… ensure that a determination, finding, or agreement under the procedures in this subpart is supported by sufficient documentation to enable any reviewing parties to understand its basis” [36 CFR § 800.11].”
I respectfully request your consideration of these concerns and the need for an onsite meeting and discussion which is being requested by so many. I urge you to halt all action on the Sugarhouse development project until this meeting and a final and informed decisionmaking process and outcome can be achieved.
